Davis v. Ayala
Davis v. Ayala, 576 U.S. 257 (2015), was a case in which the Supreme Court of the United States upheld a death sentence of a Hispanic defendant despite the fact that all Blacks and Hispanics were rejected from the jury during the defendant's trial. The case involved a habeas corpus petition submitted by Hector Ayala, who was arrested and tried in the late 1980s for the alleged murder of three individuals during an attempted robbery of an automobile body shop in San Diego, California in April 1985. At trial, the prosecution used peremptory challenges to strike all Black and Hispanic jurors who were available for jury service. The trial court judge allowed the prosecution to explain the basis for the peremptory challenges outside the presence of Ayala's counsel, "so as not to disclose trial strategy". Ayala was ultimately sentenced to death, but he filed several appeals challenging the constitutionality of the trial court's decision to exclude his counsel from the hearings.
| Davis v. Ayala | |
|---|---|
Supreme Court of the United States | |
| Argued March 3, 2015 Decided June 18, 2015 | |
| Full case name | Ron Davis, Acting Warden, Petitioner v. Hector Ayala |
| Docket no. | 13–1428 |
| Citations | 576 U.S. 257 (more) 135 S. Ct. 2187; 192 L. Ed. 2d 323 |
| Argument | Oral argument |
| Case history | |
| Prior | Ayala v. Wong, 756 F.3d 656 (9th Cir. 2013); cert. granted, 135 S. Ct. 401 (2014). |
| Subsequent | Rehearing denied, 136 S. Ct. 14 (2015); on remand, Ayala v. Davis, 813 F.3d 880 (9th Cir. 2016); Ayala v. Chappell, 829 F.3d 1081 (9th Cir. 2016); cert. denied, 138 S. Ct. 244 (2017). |
| Holding | |
| Although the defendant's attorney was excluded from a Batson hearing, any error that may have occurred was harmless because the defendant did not suffer actual prejudice | |
| Court membership | |
| |
| Case opinions | |
| Majority | Alito, joined by Roberts, Scalia, Kennedy, Thomas |
| Concurrence | Kennedy |
| Concurrence | Thomas |
| Dissent | Sotomayor, joined by Ginsburg, Breyer, Kagan |
| Laws applied | |
| Antiterrorism and Effective Death Penalty Act of 1996, 28 U.S.C. § 2254(d) | |
In a 5–4 opinion written by Justice Samuel Alito, the Supreme Court held that even if the trial court committed error, the error was harmless and that Ayala did not suffer any actual prejudice. Justice Sonia Sotomayor wrote a dissenting opinion in which she argued that Ayala's sentence should be reversed because the exclusion of Ayala's counsel from the hearings "substantially influenced the outcome" of the case. Additionally, Justice Anthony Kennedy wrote a separate concurring opinion in which he questioned the propriety of Ayala's placement in solitary confinement. In response, Justice Clarence Thomas wrote a one-paragraph concurring opinion in which he stated that Ayala's accommodations were "far sight more spacious than those in which his victims ... now rest".
Commentators have described the case as "important" and note that will likely have a "significant effect" on similar cases in the future. However, some analysts have described the outcome as "particularly unjust". Justice Kennedy's concurring opinion also received significant coverage from the media, and some analysts suggested that solitary confinement may become a "new battleground" for Justice Kennedy. One commentator described Justice Kennedy's concurring opinion as "the single most surprising and heartening development of the term".